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International tax course

Very excited as start the 2013 summer session of Seminar Acctg 659 at SDSU, starting Monday, July 8, 2013!

This is part of the syllabus for the course…

The global economy is an economic reality and taxes are a key component of the global economy as they are paid by taxpayers and fund governments. The United States of America (“US”) has the highest federal corporate tax rate of any OECD country. The highest US corporate income tax rate is 35% and the highest US federal individual tax rate is 39.6%. When you factor in state income taxes, the corporate and individual tax rates are even higher than these amounts if the US person is subject to state income taxes. Taxpayers have a moral and ethical obligation to pay the appropriate amount of taxes – no more, no less.

As students learned in Accounting 321 and Accounting 503, taxation is complex and that understanding the US tax rules is critical to informed decision-making for US taxpayers. This course is the comprehensive study of the federal US tax rules as they apply in an international tax context. Topics include: taxation of US persons; taxation of non-US persons; source of income; FDAP income and withholding; inbound taxation; outbound taxation; foreign tax credits; the role of tax treaties; US anti-deferral regimes and transfer pricing.

Course Objectives: The primary objective is to help you understand the US International Tax rules. You will gain an in-depth understanding of the fundamentals of the US tax law in an international context and apply that understanding with international tax planning concepts. The focus of this course is the US federal income tax rules as it relates to international and cross-border transactions.

You will also use and develop higher-level skills such as the ability to analyze, synthesize and critically evaluate information and rules and then to communicate that critical learning to others in an informative, constructive and ethical manner. ++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++++ ++

Class Date (2013) Topic Reading
1 July 8 Introduction
Course Overview
Re
sidency, Sec. 911
Code: 871-877, 881-885, 911 and Regs
IRS Form(s): 1040NR, 2555, 8938, TDF90.22-1
2 July 10 Jurisdiction to Tax
Scheme of Taxation 
Code: 7701(b) and Regs.
Text: pp 16-60 (¶ 1070-1225)
3 July 15 Source of Income Code: 861-865 and Regs.
Text: pp 76-140 (¶ 2000-2245)
Case: Wodehouse (¶ 4015) 
4 July 17 Trade or Business
FDAP Withholding
Code: 871-875, 881-885, 1441-2 and Regs
Text: pp 141-179, 228-241, 260-276 (¶ 3000-3140, 4000-4045, 4110-4180)
Case: SDI Netherlands (¶ 4151)
IRS Form(s): W8-BEN, 1042 
5 July 22 Class test 1 (30 minutes)
FDAP
Earnings stripping
Branch Profits Tax 
Code: 163(j), 884(a), 897 and Regs.
Text: pp 222-227, 277-292Sec. 897 (¶ 3230-3240, 4185-4275)
IRS Forms(s): 1120-F, 5472
6 July 24 Class test 2 (30 minutes)
Foreign Tax Credit and Limitation
 Code: 901-907 and Regs.
Text: pp 302-315, 324-325, 331, 336-338, 406-428,664-681 (¶ 5000-5025, 5060, 5075-5080, 5105-5110, 5215-5275, 7000-7070)
IRS Form(s): 1116, 1118 
7  July 29 Class test 3 (30 minutes)
Tax Treaties
Code: 894
Text: pp 62-75, 181-220, 242-259, 417-484(¶ 1235-1295, 3160-3220, 4050-4102, 5380-5390)
IRS Form(s): 8833
 
8 July 31  CFC, Subpart F, 956 Code: 951-958
Text: pp 485-581(¶ 6000-6190) 
9 August 5  CFC-continued, 959, 1248 Code: 898, 959, 964, 1248, 6038, 6046
Text: pp 584-602, 603-608(¶ 6200-6230, 6240-6245)
IRS Form(s): 5471 
10 August 7  Major class test (120 minutes)  
11 August 12  Section 482 Code: 482 and Regs
Text: pp 710-760 (¶ 8000-8175) 
12 August 14  Class Presentations  
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